A key part of the CBSA's mandate is to risk assess and release all imported goods coming into Canada. The CBSA carries out these activities most often upon the goods' arrival at the border; however, in some cases, they can be done inland at licensed warehouses, including sufferance warehouses.
On , regulatory amendments supporting the eManifest initiative were published in the Canada Gazette, Part II. eManifest requirements for warehouse operators are now mandatory and the following implementation timelines apply:
- From , to , the CBSA will provide warehouse operators with a period of transition during which penalties for non-compliance will not be issued. The Agency will work closely with warehouse operators on corrective measures to help them comply with eManifest requirements.
- From , to , warehouse operators who do not comply with electronic warehouse arrival requirements may be issued zero-rated penalties (non-monetary) under the CBSA’s Administrative Monetary Penalty System (AMPS).
- After , warehouse operators who do not comply with electronic warehouse arrival requirements may be issued monetary AMPS penalties.
How they work
Privately owned and operated, sufferance warehouses are licensed by the CBSA for the short-term storage and examination, when required, of imported goods not yet released by the CBSA.
Only imported goods for which financial security have been posted are eligible to be stored in these facilities. The maximum time limit for storing goods in sufferance warehouses is 40 days, with the following exceptions:
|Exceptions to the 40-day storage time limit|
|Perishables||Maximum 4 days|
|Prescribed substances (see Atomic Energy Control Act/Regulations)||Maximum 14 days|
|Firearms, prohibited ammunition, devices, prohibited and restricted weapons, tobacco products||Maximum 14 days|
|Spirits||Maximum 21 days|
Sufferance warehouse types
There are five main types of warehouses:
- Type A (General Merchandise)
- Type B (General Merchandise)
- Type C (General Merchandise)
- Type S (Specific Commodities)
- Type PS (Private Railway Siding)
Type A (General Merchandise)
- Operated by an airline, marine or railway company, it is used for the storage of imported goods in the company's system. For example, Air Canada Cargo warehouse provides service to Air Canada. There are five sub-types for this class of warehouse:
- AA - airline company;
- AM - marine company;
- AR - railway company;
- AH - cargo handler; and
- AW - harbour commissions, stevedoring companies and others.
Type B (General Merchandise)
- Used for the storage of imported goods arriving by highway in commercial motor vehicles. There are three sub-types for this class of warehouse:
- BW - for imported goods deposited by highway carriers;
- BL- operated by highway carriers for containerized freight only; and
- BL - space in a BW warehouse leased by bonded highway carriers to deposit goods carried under their own carrier code.
Type C (General Merchandise)
- Operated by a third party for the storage, deconsolidation, and sorting of imported shipments before formal entry to Canada. There is only one sub-type for this class of warehouse:
- CW - operated by a consolidator, deconsolidator, bonded freight forwarder or customs broker.
Type S (Specific Commodities)
- Operated for the storage of a specific type of imported good arriving by any mode of transportation. There are five sub-types for this class of warehouse:
- SF - fruits and vegetables, fresh meat, fish, poultry, flowers, human plasma;
- SH - used household goods and personal effects;
- SL - operated by provincial liquor jurisdictions;
- SO - other commodities as specified on the warehouse licence; and
- SO (CSA) - Specifically for members of CSA (Customs Self Assessment) and in the highway mode only.
Type PS (Private Railway Siding)
- Railway sidings owned or operated by an importer where carloads of imported goods are held pending release by the CBSA.
Note: Each warehouse type is for commodities stored in different transportation modes and in some cases for specific commodities. For example, a warehouse only authorized for household and personal effects cannot store other types of cargo. The same applies to modes of transportation.
A sub-location code identifies the location of goods within a sufferance warehouse. Carriers, freight forwarders, and agents must include sufferance warehouse sub-location codes on cargo control documents. The sub-location codes are also required so the CBSA can provide electronic release notification to sufferance warehouse operators who participate in the Release Notification System.
How to apply to become a sufferance warehouse operator
A completed application form must be submitted to the local CBSA office that has jurisdiction over the area where the operator intends to establish a sufferance warehouse (see D-Memorandum D4-1-4 for detailed information).
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